Just wondering if anyone would be willing to share the questions or types of questions that they ask at account opening for the purpose of Customer Due Diligence.
Thanks!

I would recommend taking a look at the Banker Tools on this website: http://www.bankersonline.com/tools/tools.html#AML/BSA

Try looking at the Risk Pofile and New Account Risk Assessment Worksheet. There are probably others there too that will help you.

I looked at the tools, but most of them seemed to be geared towards business accounts. I am looking for something for personal accounts.

Do you open a lot of high risk personal accounts and are you in a high risk area? If not, I would recommend not opening that can of worms.

We do not risk rate Personal accounts at account opening, unless they are a NRA or foreign address.

Your due diligence questions for individual consumer accounts should allow you to identify:
* non U.S. persons &
* politically exposed persons.

They are the only individual accounts "subject to expanded examination overview." So, each could be subject to some enhanced due diligence questions at account inception; e.g. how long will you be in the U.S., do you have permission to work in the U.S., what are your specific connections to the government of a foreign country, etc.

Beyond that, I agree with those above who suggest due diligence on consumer customers should be risk based; i.e. this is your AML program, not your anti - petty theft program. Put your time and money into gaining information on non consumer accounts.

We are based in a college town that has quite a few international students, so we do have some higher risk accounts.
The reason we are looking to implement such a program is at the repeated insistance from our auditor. If it isn't necessary, why the push to have such a program? The NCUA has never mentioned that we NEED one, but has hinted that it would be a good idea.
Thanks for the answers so far! Can't wait to take this to the compliance officer and see what she has to say...
Thanks again!

"The reason we are looking to implement such a program is at the repeated insistance from our auditor."

That is who you need to be questioning. Ask them what is their basis for such an opinion and please forward the accompanying source and reference documents.

As noted, your non U.S. persons are a legitimate issue. You should ask them additional questions. That does not imply you need to ask all other customers additional questions.

We ask:
• Income range – used to monitor activity
• Source of deposits (I am thinking of dropping this)
• Are you an NRA
• Are you a PEP
• If person does not live or work in our immediate geographic area, why are they opening an account with us.